Global Reach. Regional Expertise.

FIA AND IFM PRIVACY STATEMENT

The Futures Industry Association (“FIA”) is the leading global trade organization for the futures, options and cleared swaps markets (the “industry”). The Institute for Financial Markets (“IFM”) is an FIA affiliate and nonprofit educational foundation that provides education, training and information about global derivatives markets. This Privacy Statement describes the personal data processing and protection measures undertaken by the FIA and the IFM (collectively, “we,” “us” or “our”) in servicing the industry.

This Privacy Statement does not address our data processing in connection with employment matters. We provide a separate privacy notice to job applicants and employees.

Information about the personal data handling practices of our subsidiary, FIA Technology Services, Inc. (“FIA Tech”), is set out in a separate document, available at www.fia-tech.com.

We collect personal data to enable us to carry out our mission.

We collect certain personal information from our members, representatives, industry contacts, stakeholders and visitors to our websites (collectively, “constituents”). The information we collect is primarily the data which you provide directly to us in the course of our relationship and is used in connection with our mission, as described below.

FIA’s mission is to support open, transparent and competitive markets; protect and enhance the integrity of the financial system; and promote high standards of professional conduct. The IFM is a nonpartisan, nonprofit educational foundation. The IFM seeks to increase public awareness and understanding of the importance to the global economy of financial markets and the financial service industry. It also works to improve the technical competence of those in the industry who deal with the public. We refer to FIA and IFM’s missions collectively as “our mission.”

We conduct the following types of activities to carry out our mission:

advocate on behalf of our constituents;

conduct research;

educate through conferences, webinars, and e-learning programs;

provide access to written resources, databases of information, unique collections of materials, and documentation;

create opportunities for constituents to grow professionally and to network at industry events and through participation in our numerous committees;

distribute information about the industry through our publications and our websites;

provide a venue, at our conferences and other meetings, for constituents to meet and learn about service providers, vendors and innovators who support the industry;

provide service provider and member directories; and

hire qualified candidates to support our organizations.

These and related activities form part of our core mission. They also are benefits we offer members of FIA and those participating in FIA or IFM’s activities.

We must collect and process certain personal data in order to carry out our mission or to fulfill certain requests you make. We process personal data in a way that is consistent with our commitment to fair and transparent information practices and our legitimate business interest in furthering our mission to constituents and the industry.

1. DEFINITIONS

The terms “using” and “processing” information refer to using cookies on a computer or subjecting the information to statistical or other analysis. The terms “using” and “processing“ also include, but are not limited to, collecting, storing, evaluating, modifying, deleting, combining, disclosing and transferring information within our organization.

“Personal information” is any information that can be used to identify an individual and may include, but is not limited to, your name, physical address, email address, phone number, member number, passport number or other national identifier, login information, marketing preferences, company affiliation, photo, or payment card information. Personal information can also include information that does not identify you but could be combined with other information in a way that enables you to be identified, such as age, gender, job title or function, profession, committee membership or participation, zip code, IP address, and current location.

“Non-personal information” is information that cannot be used or combined with other information to identify or contact you, including browser types, domain names, and statistical data involving the use of our website.

“Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with the FIA or IFM, whether by ownership or otherwise.

2. WHEN DO WE COLLECT PERSONAL INFORMATION AND WHAT TYPE OF INFORMATION IS COLLECTED?

We may collect personal information (see the definition above) when you or a representative acting on your behalf:

apply for membership with the FIA or a division thereof (or the organization that you represent applies for membership and supplies your contact details);

register or subscribe to one of our events, publications or services;

volunteer for our activities, including within a division or affiliate;

register for our educational courses or materials;

pay for a product or service offered through our websites or one of our other marketing channels;

contact us for information about us or our products or services;

apply for a position with us;

seek to become an exhibitor or sponsor at our program or event;

become a service provider to the organization;

visit our website; or

otherwise provide personal information to us.

We may collect any personal information that is necessary for legitimate business purposes when such collection and use is reasonable, given your relationship with us and your reasonable expectations for how your personal information will be used. We will use this information for the purposes for which it was collected and consistent with our mission.

We may also collect personal information from trusted third-party sources and engage third parties to collect personal information to assist us. See below for more information under “Other Entities.”

FIA collects non-personal information from its websites through the use of cookies and log-files. More information about how we use cookies and how to disable them is available here.

If we receive your personal information from someone who reasonably purports to be your representative or acting on your behalf (for example, someone at your firm or an affiliated firm), we will assume that such information is being provided to us in a manner that is compliant with applicable law, including any applicable privacy rules, and any applicable corporate policies in effect at your firm.

report results or progress in connection with our educational opportunities;

provide member, exhibitor and sponsor directories;

provide and support requested products or services;

analyze and monitor the use of our products, services and websites;

offer you other related products and services;

communicate for marketing or other member communication or satisfaction purposes;

invite you to participate voluntarily in mailings or other events, which may include product surveys or participation in industry initiatives that we announce from time to time; and

support our legal and compliance obligations.

4. ENTITIES WE SHARE YOUR PERSONAL INFORMATION WITH

In order to carry out our mission, we may share personal and non-personal information with our affiliates and vendors. These may include, but are not limited to, FIA Tech and affiliated service companies that perform business and administrative operations for FIA and IFM. For example, FIA and IFM may share personal information to make it possible for a registrant of an FIA event to receive communications about IFM’s products or services, or vice versa.

Third-Party Service Providers

We may also share your personal data with third-party service providers, as necessary to carry out our mission and legitimate business functions. These service providers may include: database management platforms, credit card processors, and data storage and web-hosting companies. Our service providers are prohibited from using your personal information for any reason other than to provide the specific products or services needed to facilitate or support FIA or IFM’s business.

Event Attendees, Sponsors and Exhibitors

Should you attend one of our conferences or other events, we may share your business contact information with current or prospective attendees, sponsors, or exhibitors as part of a registration roster or interactive mobile application. Generally, we limit such information to your name, title, firm and office location. We may take photos and recordings of our conferences and programs and those in attendance and use the recorded media to publicize the conference or program. We may post the photos on our website, to social media or other public forums. We consider your attendance at our events as evidencing your consent to our use of such recorded media.

Media, Data Services and Training Programs

We may share with advertisers and/or our third-party editors aggregated statistical information about our subscribers to our magazines, news outlets, data services or training programs and information about the ways in which they use our products and services. This information does not identify subscribers personally. We use this information for market research purposes and to improve the quality of the products and services we offer. We reserve the right to disclose aggregated, non-personally identifiable information collected from our constituents to third parties for any purpose.

Other Entities

We also may disclose your personal information to:

compilers of membership directories;

payment networks and the members of such networks;

courts, independent auditors, law enforcement agencies and other governmental authorities, bodies or agencies in response to subpoenas, to prevent fraud, or during the course of an audit or examination, or as otherwise required by law or requested by competent authorities;

collection agencies, credit reporting agencies, business credit bureaus or other parties associated with collecting any debt owed to us;

service providers that support our human resources, accounting and payroll departments; and

entities or persons to whom we transfer the whole or any part of our business.

We require that these service providers protect the privacy of your personal information consistent with this Privacy Statement and agree not to use or disclose your personal information for any purpose other than to provide the products or services for which we contracted or as required by law.

5. HOW WE STORE YOUR PERSONAL INFORMATION

We transmit, collect, and store your personal information in all of the jurisdictions where we have offices in order to provide you with the benefits of membership. At present, we have offices in the United States, the United Kingdom, Belgium, the Netherlands and Singapore, as well as an affiliated entity in Japan. Potential data processing sites include jurisdictions (such as the United States and Japan) which do not have data protection laws as strict as other jurisdictions in which we operate (such as the United Kingdom, Belgium and Singapore).

As a global organization, we understand our obligations under the data protection and privacy laws of the jurisdictions in which we operate, and we take all efforts to comply. We also seek to conform with data protection and privacy best practices and international guidelines.

6. HOW WE PROTECT INFORMATION YOU GIVE US

Within FIA, IFM, and our affiliates, we restrict access to your personal information to those employees who need to know that information. We have implemented appropriate technical and administrative processes to protect personal data that are commensurate with the sensitivity of the information collected. Recognizing that technology is continually developing, we implement new procedures and technology improvements on an ongoing basis, as appropriate, to further safeguard your personal information.

We would like to inform you by e-mail, mail or telephone about our services and events that may interest you using the contact information you provide us. We find that our constituents expect to receive information on our range of services.

If you or your representative provides us with your contact information, we treat that as an affirmative act that evidences your consent to send you information about FIA’s services and events and any other correspondence that a person would reasonably expect to receive from a member-based trade association and its affiliates. However, you may request at any time that we cease contacting you regarding any services or offerings. Additionally, you may request, subject to our business needs and legal obligations, that we not share your contact information with third parties in connection with our events and services.

You may unsubscribe at any time from our communications by updating your communication preferences, which can be accessed through your personal account on the FIA website.

Additionally, you may request that we remove your name from our system or amend or update inaccurate or stale data in our system. Our ability to honor that request is subject to our legal obligations and our business needs. Also, you may at any time rescind any consent(s) you have previously provided regarding our processing of your personal information.

Any such requests can be made by any of the methods set out below in the “How to contact us.” Section.

8. WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONAL INFORMATION?

Except as otherwise described in this Privacy Statement or separate agreement, as applicable, we will only use personal information for the purposes described above or as otherwise disclosed at the time we request such information from you. We will use your personal information for any other purpose only with your consent.

9. CAN I HAVE MY INFORMATION UPDATED, CORRECTED OR DELETED?

You may request that we: (1) update or correct your personal information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personal information maintained about you on our systems (subject to our data retention policies, described in the following section). Such updates, corrections, changes, and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Statement prior to such update, correction, change or deletion.

To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

We will implement your request as soon as and to the extent reasonably and technically practicable. We may not be able to honor all requests when personal information must be retained for business purposes or to comply with applicable law.

10. RETENTION OF PERSONAL INFORMATION

FIA will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our business requirements and legal obligations, resolve disputes, protect our assets, and enforce our agreements.

11. COOKIES

As with most websites, our websites may use small pieces of code called “cookies” to log certain information from each visitor to the sites. When you first visit our websites, we may send you a cookie. A cookie is a small file that can be placed on your computer’s hard drive for record-keeping purposes. The data collected is not personal to you and is gathered only on an aggregate basis. In general, we use cookies to help measure traffic to different parts of our websites, improve our content, offer members-only discounts and content, and prevent malicious activity. More detailed information on our use of cookies is available.

12. OTHER WEBSITES

Our websites may contain links to other websites. Our privacy policies and this Privacy Statement only apply to our websites. When you link to other websites you should read their own privacy policies.

13. CHANGES TO OUR PRIVACY STATEMENT

We will periodically review our privacy policies and update this Privacy Statement to reflect any material changes. This Privacy Statement was last updated on 16 May 2018.

14. HOW TO CONTACT US

You may contact us if you have any questions about our privacy policies or the personal data we hold about you. Although we make these requests a priority, it may take a number of days from receipt of your request for us to respond.

We will respond to your inquiries as soon as reasonably practicable after we receive them. Citizens of the EU may have an opportunity to have their complaints heard before an EU data protection authority in the event that FIA is unable to satisfactorily resolve their complaints.

16. APPLICABLE LAW

The laws of the United States, and, in particular, the State of New York, govern this Privacy Statement.